1. The plaintiff's claim is dismissed.

2. The costs of lawsuit shall be borne by the Plaintiff.

1. Details of the disposition;

A. B Co., Ltd. (hereinafter “Nonindicted Company”) is a company that runs a general book and textbook publishing business on January 15, 1990.

B. C, who served as the representative director of the non-party company, transferred 60,000 shares of the non-party company owned by himself on November 15, 2004 to the officers and employees of the non-party company including the plaintiff, and completed the transfer of title.

C. The Defendant: (a) applied Article 45-2(1) of the former Inheritance Tax and Gift Tax Act (amended by Act No. 8828, Dec. 31, 2007; hereinafter “former Inheritance Tax Act”) on the ground that the Plaintiff received title trust from Nonparty Company D, the actual owner of the shares; (b) decided and notified the Plaintiff of KRW 17,206,240 (including additional taxes) of gift tax.

(hereinafter “instant disposition”) D.

On April 20, 2015, the Plaintiff filed an appeal with the Tax Tribunal on April 20, 2015, but was dismissed on August 12, 2015.

[Ground of recognition] Facts without dispute, Gap evidence Nos. 1, 2, 11, Eul evidence Nos. 1 and 12 (including additional numbers), the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The Plaintiff asserted that the pertinent shares were held in title by E religious organizations, not D individuals. Since E religious organizations are exempt from taxation for profit-making businesses in practice as religious organizations, there is no room for recognizing the purpose of tax avoidance.

On the other hand, the E religious organization held in trust the shares of the non-party company, including the plaintiff, for reasons such as the question whether the religious organization can become a shareholder of the non-party company that carries out profit-making business, the concerns that the non-party company may suffer disadvantages if the non-party company becomes an entity operated by the E religious organization, and the awareness that the non-party company or its officers and employees may suffer disadvantages, and the inspiring self-esteem of believers.

B. Entry in the relevant statutes attached thereto and the relevant statutes.